Legal Opinion
Levy v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided November 30, 1942No. 12PublishedCited by 21 opinions
1Opinion of the Court
CHASE, Circuit Judge.
The sole issue is whether the owner of a debt, which was admittedly a capital asset at the time of sale, who sold it in 1937 for $13,283.84 less than its face value and at the end of that year, which was several months after the sale, charged off on his books the above portion of the debt as partially worthless may. deduct that entire amount under § 23(k) of the Revenue Act of 1936, 26 U.S.C.A. Int.Rev.Acts, p. 828, or is limited to a deduction of $2000 for a capital loss under § 117 of the same Act. The Commissioner determined a deficiency in the income taxes of the…
2Cases cited2 opinions
- Hellmich v. HellmanSupreme Court of the United States · 1928
- Missouri v. RossSupreme Court of the United States · 1936
3Cited by21 opinions
- Stoddard v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1944
- John Wanamaker Philadelphia v. Com'r of Int. RevenueCourt of Appeals for the Third Circuit · 1943
- Bird Management, Inc. v. CommissionerUnited States Tax Court · 1967
- J. E. Hawes Corp. v. CommissionerUnited States Tax Court · 1965
- Levine v. CommissionerUnited States Tax Court · 1959
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